Employment forms and labour management that meet the staffing standard for employment continuation support Type A and Type B

Bottom line first: The staffing standard for employment continuation support Type A and Type B is judged not by "how many staff you place" but by "whether the full-time equivalent is enough for the number of users". So designing the scheduled hours of non-full-time and part-time staff, and keeping duty records, tie directly to keeping the designation. Vocational instructors and life-support workers must number, by full-time equivalent, at least the user count divided by ten, at least one of each and at least one full-time; a service-management manager is one or more for up to sixty users.

The biggest difference is the employment contract. Type A concludes an employment contract with the user, so that user is treated as a worker subject to the minimum wage, social insurance and working time. Type B pays a work reward without concluding an employment contract.

The designation application itself belongs to a Gyoseishoshi, the design of the reward (National Health Insurance Federation billing) scheme to a Gyoseishoshi and the operator, and the corporation's accounting and tax to a tax accountant. What this office takes on is labour and social-insurance support; individual determinations are made by a qualified professional after a consultation.

How do the staffing standard and the idea of employment differ between Type A and Type B?

The skeleton of the staffing standard (vocational instructor, life-support worker, service-management manager, manager) is common to Type A and Type B, but the user's position differs. Type A concludes an employment contract between the office and the user; Type B does not. The designation standard is set in Article 186 onwards of Ministry of Health, Labour and Welfare Ordinance No. 171 of 2006 for Type A, and Article 199 onwards for Type B.

Issue	Type A	Type B
Relation with the user	Concludes an employment contract (standard Article 190)	Pays a work reward without an employment contract
Vocational instructor and life-support worker	Full-time equivalent of at least user count ÷ 10; at least one of each, at least one full-time (Article 186)	Full-time equivalent of at least user count ÷ 10; the same (Article 199)
Service-management manager	One or more for up to sixty users; add one for every forty (or fraction) beyond sixty; at least one full-time	The same idea as Type A
Manager	One per office; concurrent post allowed where there is no hindrance	Same as left
What is paid to the user	Wages (subject to the Minimum Wage Act)	A work reward

A Type A user who has concluded an employment contract is a worker subject to the Labor Standards Act and other labour-related laws. This leads to the burden unique to Type A: on top of managing the labour of staff, the labour of "users = workers" arises at the same time. The reward scheme has a category that chooses a thicker placement (one staff member for every 7.5 users, for example), but that is a matter of the reward, separate from the minimum line of the designation standard. The minimum line for meeting the designation is "at least the number divided by ten".

How are non-full-time and part-time staff counted to meet the full-time equivalent?

Placement is counted by the "full-time-equivalent method". Full-time equivalent means dividing the total working hours of staff by the hours a full-time staff member is to work at that office, converting into full-time equivalents. In other words, whether the standard is met turns not on how many part-timers are hired but on how many full-time equivalents the total working hours amount to.

Design point	What to decide on the labour side
Full-time scheduled hours	Make clear in the work rules the hours a full-time staff member is to work
Non-full-time and part-time scheduled hours	State scheduled hours and days in the employment contract (Labor Standards Act Article 15(1); Enforcement Ordinance Article 5)
Full-time-equivalent calculation	Each person's total working hours ÷ the hours a full-time member is to work
Records	Keep both the duty schedule and duty records (time cards and the like)

Disclosure of working conditions is a duty under Article 15(1) of the Labor Standards Act, and the items to be disclosed are set out in Article 5 of the Enforcement Ordinance. Because some items require disclosure in writing (including electronic delivery where the worker so requests), do not leave it to oral exchange alone. Where working-time management is lax, the full-time-equivalent figure falls below the standard, leaving the office short of the designation standard. Duty records are labour management and, at the same time, documents for maintaining the designation. On the thinking behind social insurance when hiring for short hours, see When you hire for short hours, what happens to social insurance.

How far is a concurrent post allowed for a service-management manager or vocational instructor?

Whether a concurrent post is allowed rests on not breaking the full-time-equivalent figure and securing the time each duty needs. A manager may be allowed a concurrent post with another duty where there is no hindrance to the management work, but the time counted as a vocational instructor or life-support worker and the time as a manager cannot be double-counted.

Type of concurrent post	Idea
Manager and service-management manager	A concurrent post may be allowed where there is no hindrance, but the full-time equivalent cannot be double-counted
Vocational instructor and life-support worker	At least one of each is separately required; one person cannot fill both slots at once
Full-time double-count	The same working hours are not counted across multiple roles

Which concurrent posts are specifically allowed turns on the municipality's practice and the office's duty roster. This article stays with the general idea and does not conclude on a particular concurrent post. As a starting point for the relation between work form, working time and wages — using the example of a disability group home — see also The treatment of working time differs between night duty and on-call at a disability group home. The duty to draw up work rules itself is set out in From how many workers are work rules mandatory, and what is not mandatory.

As workers, how are Type A users treated for the minimum wage and social insurance?

Because Type A concludes an employment contract with the user, that user is a worker subject to the Minimum Wage Act. Wages at or above the minimum wage must be paid (Minimum Wage Act Article 4), and where there are circumstances such as markedly low working ability due to a disability, there is an exception under which the minimum wage may be reduced by a certain rate with the permission of the director of the prefectural labour bureau (Minimum Wage Act Article 7). Wages below the minimum wage cannot be set without permission.

Issue	Type A (with employment contract)	Type B (no employment contract)
What is paid	Wages (subject to Minimum Wage Act Article 4)	A work reward
Reduction of the minimum wage	Permission of the prefectural labour bureau director is required (same Act Article 7)	Not wages, so outside the Minimum Wage Act framework
Social insurance	As a worker, subject to health insurance, employees' pension and employment insurance where requirements are met	No employment relation; the user is not an insured person of labour or social insurance
Working time and breaks	Subject to the Labor Standards Act	Not a worker under the Labor Standards Act

Whether a Type A user enrols in health insurance and employees' pension is judged by the same axes as for staff (the three-quarters standard and the short-hour worker coverage expansion). For employment insurance, 20 hours a week is the dividing line. Because wage design changes depending on whether the reduction exception is permitted, the point is to keep the work rules, wage rules and employment contract consistent with actual working hours. However, whether the reduction exception is permitted for a particular user, and at what rate, is not concluded in this article.

Who should handle the labour of staffing, and who the designation application?

Preparing to open and run splits by responsible entity.

Issue	In charge
Employment contracts of staff and Type A users, work rules and wage rules, duty rosters mindful of the full-time equivalent, social- and labour-insurance procedures	Shakai Hoken Roumushi (this office)
Designation application, change notifications and other municipal procedures; design of the reward (National Health Insurance Federation billing) scheme	Gyoseishoshi and the operator
Selecting and leasing the premises for the office	Real estate
The corporation's accounting and tax	Tax accountant
Registration of the office	Judicial scrivener

The designation application is Gyoseishoshi work, and 四葉行政書士事務所 is a business entity independent of this office. Premises are accepted by 四葉不動産株式会社, also as a separate business entity. Where needed, we introduce them under a separate contract that you conclude directly, and this office takes no referral fee.

What can 四葉社会保険労務士事務所 do?

What this office takes on is designing the labour side that meets the staffing standard, and maintaining it.

• Drawing up employment contracts reflecting the scheduled hours of full-time and non-full-time staff (including the employment contract with Type A users)
• Designing duty rosters and shifts with the full-time equivalent in mind, and organising duty records
• Preparing work rules and wage rules
• Judging and processing enrolment in social and employment insurance for staff and Type A users
• Designing the management of working time, breaks and overtime

The following are not handled here.

• Designation applications, change notifications and other municipal procedures, and design of the reward (National Health Insurance Federation billing) scheme → 四葉行政書士事務所 accepts these as a separate business entity
• Selecting and leasing the premises for the office → 四葉不動産株式会社 accepts this as a separate business entity
• The corporation's accounting and tax → we connect you with a tax accountant (Zeirishi)
• Registration of the office → we connect you with a judicial scrivener (Shiho Shoshi)

四葉不動産株式会社, 四葉行政書士事務所 and 四葉社会保険労務士事務所 each accept work as an independent business entity, under a separate contract. Where another professional is introduced, you contract with them directly, and this office receives no referral fee.

Consultations are free of charge. Fees are set out in the fee schedule; see also our services and how a consultation proceeds.

Frequently asked questions

Q. Does the staffing standard for staff differ between Type A and Type B?
A. The skeleton of the staffing standard for staff (vocational instructors and life-support workers at a full-time equivalent of at least user count ÷ 10, at least one of each and at least one full-time; a service-management manager for up to sixty users) is a common idea for Type A and Type B. What differs is the user's position: Type A concludes an employment contract with the user (standard Article 190), Type B does not. Even though the staff-side standard is the same, Type A adds the labour management of users as workers.

Q. Can the staffing standard be met with part-time staff alone?
A. If the full-time-equivalent figure is met, meeting the standard through a combination of non-full-time and part-time staff is itself possible. However, at least one vocational instructor and at least one life-support worker are required, and at least one of them must be full-time. Trying to run on part-timers alone without a full-time member fails this full-time requirement. Making clear in the work rules "the hours a full-time member is to work" is the premise of the full-time-equivalent calculation.

Q. Do Type A users have to be paid the minimum wage?
A. Because Type A concludes an employment contract with the user, that user is a worker, and wages at or above the minimum wage must be paid (Minimum Wage Act Article 4). Where there are circumstances such as markedly low working ability due to a disability, there is an exception under which the minimum wage may be reduced by a certain rate with the permission of the prefectural labour bureau director (same Act Article 7). Wages below the minimum wage cannot be set without permission. Whether it is permitted for a particular user, and at what rate, is not concluded in this article.

Q. Are work rules needed even with fewer than ten staff?
A. The duty to draw up and file under Article 89 of the Labor Standards Act arises at a workplace ordinarily employing ten or more workers. With fewer than ten, that duty itself does not arise. But arranging "the hours a full-time member is to work" (the premise of the full-time equivalent) and the idea of wages including Type A users as rules is often practically necessary regardless of headcount. Think of the mandatory work rules and the rules arranged for operation as having different purposes.

Basis for this article

• Standards concerning staff, equipment and operation of designated disability welfare services under the Act on Comprehensive Support for the Daily and Social Life of Persons with Disabilities (Ministry of Health, Labour and Welfare Ordinance No. 171 of 2006) Article 186 — staff of employment continuation support Type A (vocational instructors and life-support workers at a full-time equivalent of at least user count ÷ 10, at least one of each and at least one full-time; a service-management manager for up to sixty users, adding one for every forty or fraction beyond sixty) (confirmed 27 August 2026 from the Ministry's interpretation notice, municipal guidance and WAM materials)
• Same standards ordinance, Article 190 — a Type A operator must conclude an employment contract with the user (a user who has concluded an employment contract is a worker subject to the Labor Standards Act and other labour-related laws; interpretation notice Shohatsu No. 1206001 of 6 December 2006)
• Same standards ordinance, Article 199 — staff of employment continuation support Type B (vocational instructors, life-support workers and service-management manager placed on the same idea as Type A; Type B pays a work reward without an employment contract)
• Minimum Wage Act (Act No. 137 of 1959) Article 4 — an employer must pay a worker to whom the minimum wage applies wages at or above the minimum wage amount
• Same Act, Article 7 — for a person whose working ability is markedly low due to a mental or physical disability and the like, the minimum wage may be applied reduced by a certain rate where the employer obtains the permission of the prefectural labour bureau director (reduction exception)
• Labor Standards Act (Act No. 49 of 1947) Article 15(1); Enforcement Ordinance Article 5 — disclosure of working conditions (the items and disclosure in writing and the like)
• Same Act, Article 89 — duty of an employer ordinarily employing ten or more workers to draw up and file work rules
• Short-hour workers' social insurance — the three-quarters standard, and, at a specified applicable workplace, the requirements of 20 or more hours a week, monthly wages of 88,000 yen or more, expected employment of more than two months, and not a student (Employees' Pension Insurance Act and Health Insurance Act; confirmed 27 August 2026)
• On the reward side of employment continuation support there is a category rewarding a thicker placement (one staff member for every 7.5 users and the like), but this is a category of the reward notice, separate from the minimum line of the designation standard. The selection of a reward category by office and by year is not covered here (unverified)
• Whether a concurrent post is allowed, and the finer method of full-time-equivalent calculation (rounding of fractions and the like), depend in part on each municipality's practice and guidance; individual determinations are not covered here (unverified)
• The competent authority and article numbers of the standards ordinance can change by amendment. Before a designation application, confirm against the municipality's latest guidance and the ordinance text (unverified)

This article is general information. Individual determinations are made by a qualified professional after a consultation, in light of individual circumstances. 四葉社会保険労務士事務所 can advise on drawing up employment contracts reflecting the scheduled hours of full-time and non-full-time staff (including the employment contract with Type A users), designing duty rosters mindful of the full-time equivalent and organising duty records, preparing work rules and wage rules, judging and processing social- and employment-insurance enrolment for staff and Type A users, and designing the management of working time, breaks and overtime. Designation applications, change notifications and the design of the reward (National Health Insurance Federation billing) scheme are accepted by 四葉行政書士事務所 as a separate business entity, and selecting and leasing the premises by 四葉不動産株式会社 as a separate business entity, each contracted separately. The corporation's accounting and tax are matters we connect you with a tax accountant (Zeirishi) for, and registration with a judicial scrivener (Shiho Shoshi). If a different professional is needed, each is contracted separately, and there is no referral fee. Frequently asked questions are collected in the FAQ. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).